Children’s privacy notice.

This notice describes how we handle information about children under 13 years of age who use Twiggybank as part of a family account. It is written to comply with the United States Children’s Online Privacy Protection Act (COPPA) and similar laws elsewhere. If you are a parent or legal guardian, this notice is for you.

Children do not create their own Twiggybank accounts. A parent or guardian adds them to a family, controls what information is stored about them, and may give them limited login access on the parent’s judgment.

We do not collect or store:

• The child’s real legal name (beyond the display name).
• The child’s address, phone number, or other contact details.
• Photographs or video of the child.
• Geolocation data more precise than the family’s configured time zone.
• Behavioral or advertising profiles. Twiggybank shows no advertising of any kind to anyone, child or adult.

We do not knowingly collect more information about a child than what is listed in Section 02. If we discover that we have, we will delete it.

We use the information we hold about a child only to:

• Run the family ledger (compute balances, post payday entries, accrue interest).
• Authenticate the child if their parent has enabled a login.
• Show the child’s own data to the child and the parent.
• Keep the service operational (fix bugs, prevent abuse).

We do not use children’s information for marketing or advertising. We do not use it to train machine-learning models. We do not sell or rent it.

The only third parties who see children’s data are the service providers that operate the underlying infrastructure (our hosting and database providers, named in the Privacy Policy). They process the data only to provide their services to us, and only under contracts that protect it.

We may also disclose information when required to do so by law. We will tell you if this happens, unless we are legally prohibited from doing so.

By creating a Twiggybank family and adding a child, you consent to the collection and use of that child’s information as described in this notice. You are confirming that you are the child’s parent or legal guardian and that you have the authority to provide that consent.

We do not collect any information about a child until a parent has added them. The parent remains the controller of the child’s data inside our service.

As the parent or guardian, you have the right to:

• Review what we have collected about your child. Most of this is visible inside the app already.
• Correct any information that is inaccurate.
• Delete your child’s information by archiving the child in the app, or by writing to us to delete them entirely.
• Withdraw your consent at any time. Withdrawing consent removes the child from Twiggybank.

To exercise any of these rights, write to privacy@twiggybank.com from the email address on your parent account. We’ll confirm the request and act on it within 30 days.

We keep a child’s data for as long as the family account remains active and the child has not been archived. If you archive a child, their personal information is hidden from the app but the ledger entries they participated in remain visible to the parent, because removing them would silently change the family’s historical record.

If you request full deletion of a child — not just archival — we will delete the personal information (display name, birthday, color, login credentials) and either anonymize or delete the associated ledger entries, depending on what the parent prefers. We’ll discuss the trade-off with you over email before we act.

We protect children’s information the same way we protect everyone else’s, plus a few extras: children’s data is never used for analytics, never shown to third parties for any reason other than running the service, and never used to train models. For the full description of our security posture, see our Security page.

If we change this notice in any way that affects how we collect or use children’s information, we’ll notify the parent on the account by email before the change takes effect. For non-material edits we may quietly update.

To ask questions, raise a concern, or exercise any of the rights described above, write to privacy@twiggybank.com. A real person will read it and respond.